View source for CP-200800655, Submittal of the Annual Non-Radiological Environmental Operating Report for 2007

{{Adams
| number = ML081340349
| issue date = 05/06/2008
| title = Submittal of the Annual Non-Radiological Environmental Operating Report for 2007
| author name = Flores R
| author affiliation = Luminant Generation Co, LLC, Luminant Power
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000445, 05000446
| license number = NPF-087, NPF-089
| contact person = 
| case reference number = CP-200800655, TXX-08075
| document type = Environmental Monitoring Report, Letter type:CP
| page count = 12
}}

=Text=
{{#Wiki_filter:U                                               Rafael Site  Vice Flores President rafael.flores@luminant.com Luminant P 0 Box 1002Power 6322 North FM 56 Luminant                                                                                    Glen Rose, TX 76043 T 254 897 5590 C 817 559 0403 F 254 897 6652 CP-200800655 Log # TXX-08075 May 6,2008 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

==SUBJECT:==
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445/446 SUBMITTAL OF THE ANNUAL NON-RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT FOR 2007

==Dear Sir or Madam:==

Luminant Generation Company LLC (Luminant Power) hereby submits for Comanche Peak Steam Electric Station, herein referred to as Comanche Peak Nuclear Power Plant (CPNPP), the enclosed copy of the Annual Non-Radiological Environmental Operating Report for the CPSES Radiological Environmental Monitoring Program. This report is submitted pursuant to Appendix B of the CPSES Unit 1 and 2 Operating License Nos. NPF-87 and NPF-89. The report covers the period from January 1, 2007 through December 31, 2007 and summarizes the results of measurements and analysis of data obtained from samples collected during this interval.
If there are any questions regarding this report, contact Neil Harris at (254) 897-5449 or Bruce Turner at (254) 897-8901.
This communication contains no new licensing basis commitments regarding CPNPP Units 1 and 2.
Sincerely, Luminant Generation Company LLC R~af1ael Flores Site Vice President

U. S. Nuclear ReguLatory Commission TXX-08075 Page 2 05/06/2008 Enclosure         - Annual Non-Radiological Environmental Operating Report for 2007 c-         E. E. Collins, Region IV B. K. Singal, NRR Resident Inspectors, Comanche Peak

TXU GENERATION COMPANY LP (TXU POWER)
COMANCHE PEAK NUCLEAR POWER PLANT UNITS 1 & 2 2007 ANNUAL ENVIRONMENTAL OPERATING REPORT (NON-RADIOLOGICAL)
FACILITY OPERATING LICENSE NOS. NPF-87 & 89 I

INTRODUCTION This report describes implementation of the Environmental Protection Plan (EPP) for the calender year 2007 as required by Appendix B to Facility Operating License Nos. NPF-87
     & 89 for Comanche Peak Nuclear Power Plant (CPNPP) for Units 1 & 2.
During 2007, the CPNPP Nonradiological Environmental Monitoring Program was effective in implementing and monitoring all CPNPP environmental regulatory commitments.
Program effectiveness in 2007 was substantiated by Luminant Corporate environmental audits and compliance evaluations of the CPNPP environmental program.
SCOPE Section 5.4.1 of the EPP requires that CPNPP submit to the NRC an Annual Environmental Operating report that shall address the following environmental protection activities:
A.      Summaries and analyses of the results of the environmental protection activities required by Section 4.2 of the EPP, including a comparison with related preoperational studies, operational controls (as appropriate), and previous nonradiological environmental monitoring reports, and an assessment of the observed impacts of plant operation on the environment. If harmful effects or evidence of trends toward irreversible damage to the environment are observed, a detailed analysis of the data and a proposed course of mitigating action is required.
Section 4.2 of the EPP pertains to results from:
: 1.      Groundwater levels and station water use monitoring.
: 2.      Water treatment facility outages impact assessment and reporting.
B. The report shall also include:
: 1.      A list of EPP noncompliances and the associated corrective actions.
: 2.      A list of all changes in station design and operation, tests, and experiments made in accordance with Subsection 3.1 of the EPP which involved a potentially significant unreviewed environmental question.
: 3.      A list of nonroutine reports submitted in accordance with Subsection 5.4.2 of the EPP.
: 4.       A summary list of Texas Pollutant Discharge Elimination System (TPDES) permit related reports relative to matters identified in Subsection 2.1 of the EPP which were submitted to the Texas Commission on Environmental Quality (TCEQ) during the report period. Subsection 2.1 of the EPP pertains to aquatic matters that are addressed by the effluent limitations, and the monitoring requirements contained in the TCEQ TPDES station wastewater discharge permit.
III. RESULTS OF ACTIVITIES A. As required by Subsection 4.2 of the EPP, the following are summaries and analyses of the environmental protection activities during 2007. Based on the results 2

of these activities, there were no observed adverse environmental impacts resulting from plant operation during 2007.
Groundwater Pumpage As indicated in Table 1, groundwater pumpage during 2007 averaged 15.8 gals./min. (gpm) or 8,279,900 total gallons withdrawn for the year. This withdrawal rate represents a 8.8% decrease from the 2006 average rate of 17.3 gpm. Groundwater withdrawal was highest in February at 25.1 gpm and lowest in June and December with an average monthly withdrawal rate of 12.4 gpm.
Groundwater withdrawn during 2007 was used primarily for potable and sanitary purposes with only a very small amount used as make-up to the plant fire protection system. No groundwater was used to supplement the station's Surface Water Treatment System.
The average annual pumpage rate of 15.8 gpm for 2007 represents 12.4%
of the predicted operational pumpage (127 gpm) identified in Section 3.3 of the Station's Environmental Report - Operational License Stage. This rate also represents approximately 10.0 % of the actual average withdrawal rate (158 gpm) reported in the Station's Final Environmental Statement -
Operating License Stage (Section 5.3.1.2) for the period 1975 to May 1979.
The combined annual rate for all recorded pre-operational groundwater pumpage averaged 68.8 gpm, while the average operational pum page for the period 1990 through 2007 was 24.7 gpm. Therefore, the average operational rates are 64.1% less than the groundwater pumpage during the preoperational period. Figure 1 illustrates the annual fluctuation of groundwater withdrawal over the entire pre-operational and operational period.
: 2.      Groundwater Levels As indicated in Table 2, the groundwater level in the on-site observation well OB-3 (intersection of Highway 56 and the Plant Access Road) fluctuated during 2007 from a high level in July of 521.93 ft. Mean Sea Level (MSL) to a low level in January of 516.63 ft. MSL. Overall, the water level in OB-3 during the reporting period (January through December) decreased 3.1 ft.
(0.94m).
The 2007 annual average groundwater levels in wells OB-3 and OB-4 were 519.56ft. MSL and 550.23ft. MSL, respectively. These average levels demonstrated a increase of 3.5 ft. (1.07m) for OB-3 and a increase of 6.66 ft.(2.74m) for OB-4 from the respective average 2006 levels (Figure 2).
As illustrated by Table 2, ground water levels increased during the reporting period. This increase coincided with increase rainfall of 37.7 inches during 2007 as compared to 28.9 inches in 2006.
3 I
: 3. Surface Water Treatment System Operation The station's Water Treatment System processed 221,263,300 total gallons (421 gpm) of surface water during 2007 for plant process use. There were no outages during 2007 that required reporting in accordance with Section 4.2.2 of the EPP.
The following is a summary list of monthly surface water usage:
MONTH
_   I?*'SURF ACE 'WATER PROCESSED (GALS.)
JANUARY                          18,841,800 FEBRUARY                        17,646,600 MARCH                           16,079,700 APRIL                           20,095,700 MAY                             19,327,185 JUNE                             17,978,255 JULY                             16,617,260 AUGUST                           17,512,400 SEPTEMBER                       18,117,900 OCTOBER                         19,429,000 NOVEMBER                        19,092,000 DECEMBER                        20,525,500 TOTAL                           221,263,300 B. EPP Noncompliance and Corrective Actions - Subsection 5.4.1(1)
There were no noncompliances with the requirements of the EPP during the reporting period.
C. Changes In Station Design or Operation, Tests, and Experiments Made In Accordance With Subsection 3.1 Which Involved A Potentially Significant Unreviewed Environmental Question.
There were no changes in station design, operation, tests or experiments conducted during the reporting period that are reportable under this subsection.
4

D.      Nonroutine Reports Submitted In Accordance With Subsection 5.4.2 Otherthan those nonroutine reports identified in section Ill.E, therewere no other nonroutine reports submitted under this subsection.
E.      Texas Pollutant Discharge Elimination System (TPDES) Permit-Related Reports Relative To Matters Identified In Subsections 2.1 and 5.4.1
: 1.      Routine monthly Discharge Monitoring Reports (DMR) for all wastewater outfalls were submitted to the Texas Commission on Environmental Quality (TCEQ) for each month during 2007. The following is a summary list of correspondence pertaining to DMRs and TPDES permit related documents.
MONTH                                       LGNMBRDT MONITORED6LONUBRAT JANUARY                     TXE-07041-02/20/07
 ,FEBRUARY                    TXE-07062-03/20/07 MARCH              6        TXE-07077-04-20-07 APRIL                      TXE-07093-05/22/07 MAY                        TXE-07104-06/20/07 JUNE                       TXE-07116-07/19/07 JULY                        TXE-07125-08/16/07 TXE-07119-07/19/08 AUGUST                      TXE-07135-09/20/07 SEPTEMBER                   TXE-07144-10/19/07 OCTOBER                     TXE-07166-11/15/07 NOVEMBER                6   TXE-07185-12/19/07 DECEMBER.                   TXE-08099-01/16/08 TXE-08010-01/16/08
: 2.      Routine biomonitoring was conducted semi-annually in accordance with the TPDES Permit. The tests using the fathead minnow (Pimephales promelas) were passed in accordance with all criteria. The Ceriodaphnia dubia tests continued to be invalid due to insufficient survival and neonate production in the control (intake) water. On 2 May 2008, the Company submitted a request to the Texas Commission on Environmental Quality (TCEQ).
for an alternate invertebrate species, Daphnia magna, for use in testing when the reservoir Total Dissolved Solids (TDS) concentrations are elevated. Successful testing was performed with this species with TCEQ approval during the 4th Quarter. This alternative test species is expected to be included as an option for testing at elevated TDS concentrations in the forthcoming TPDES Permit renewal.
5
: 3. There were no TPDES wastewater discharge permit noncompliances in 2007.
: 4. There were also no reportable spills during 2007.
                             ,2 6

TABLE 1

==SUMMARY==
OF GROUNDWATER PUMPAGE For 2007
                                                                                                                        ' RE/TRINIG                 .      OTAS "NO.                OF PLANT WELL 1           PLANT WELL2
___  __  __    j   NOSF WELL1-NOSF WELL 2
__             _ .1_
RETRAIN
_  -___j TOTALSNOA
                                                                                                                                                       ~DAYS, . , .        ..BETW EEN Total      Avg.                        vg.         Total         Avg.            Total Gals. Avg.,    Total Gals.         Avg. Total Gals.       Avg.. READINGS MONTH     Gals. _
J_        _ Gal.          ,           Gal. _       Gals.
_              Gal. _          _        _    _ Gal.          _                  _  _          _   _ Gal.
Per Mi.                    PerMi.                  . Per Mi                            Per                       Per Min.                Pe Min.
January      396,200        8.9    339,600             7.6       57,900           1.3             64,400         1.4          2,200          0.0       860,300       19.3        31 February     623,500      15.5     256,500             6.4       65,000           1.6             65,000         1.6          1,300          0.0     1,011,300       25.1        28 March.       650,000      14.6     239,200             5.4       58,900           1.3             61,000         1.4          1,200          0.3     1,010,300       22.6       31 April        440,000      10.2     348,900             8.1       39,000           0.9             32,100         0.7          1,200          0.1       861,200       19.9       30 May          499,900      11.2           0             0.0       52,200           1.2             56,500         1.3          1,500          0.1       610,100       13.7        31 June         181,600       4.2     245,100             5.7       52,600           1.2             55,700         1.3          1,500          0.1       536,500       12.4        30 July          71,400        1.6    593,800            13.3       39,500           0.9             48,800         1.1          1,400         <0.1       754,900       16.9        31 August       324,600       7.3           0             0.0     101,300            2.3             59,400         1.3          1,800          0.1       487,100       10.9        31 September     62,100        1.4    308,800             7.1       40,800           0.9             38,400         0.9          1,700         <0.1       451,800       10.5       30 October      345,500       7.7     155,600             3.5       40,700           0.9             40,200-        0.9          1,200         <0.1       583,200       13.1       31 November     395,200       9.1      78,900             1.8       42,700           1.0             40,400         0.9          1,700         <0.1       558,900       12.9       30 December      14,800       0.3     461,300            10.3       41,200           0.9             35,200         0.8          1,800         <0.1       554,300       12.4       31 TOTA     - 4,0,0           7][3,:027,700    j          5.8     6=31,800   j       1.2            597,100  j      1.1        18,500           0.1    8,279,900.       15.8 IF    365 7

I 'y TABLE 2 2007 

==SUMMARY==
OF GROUNDWATER LEVELS IN OBSERVATION WELLS WELL-.OB-*3.MH*                   WELL -4)
MONTH                           (G-3)(G4
[DEPTH-(1)           MSL (2)           DEPTH (1)    MSL(2)
January                           277.2             516.63          302.01      545.87 February                          276.8            .517.03          300.97      546.91 March                             276.1             517.73          299.94      547.94 April,'.                         274.82             519.01          298.13      549.75 May                               273.7             520.13           296.3      551.58.
June.%.                          272.45             521.38          294.98      552.90 July      ,                       271.9             521.93          294.11      553.77
          ,August,,                         272.55             521.28          296.32      551.56 September                         274.2             519.63          297.57      550.31 October                          273.75             520.08          298.54      549.34 November                         273.67             520.16          297.56      550.32 December                         274.10             519.73          295.35      552.53 ANNUAL GROUNDWATER LEVEL CHANGE FOR 2005:
Well OB-3:    277.2 ft. - 274.1 ft = 3.1ft. = 0.94 m (increase)
Well OB-4:    302.01 ft. - 295.35 ft = 6.66 ft. = 2.03 m (increase)
NOTES:
(1)   Depth to water table (ft.)
(2)   Water table elevation (ft.) Mean Sea Level (MSL) 8

Attachment to TXX-OSO7S Page 8of 9 FIGURE 1

==SUMMARY==
OF GROUNDWATER PUMPAGE 1975 THROUGH 2007 (GPM)
Annual Groundwater Pumpage 200 180 160 140 -4n 120 100 0.
80 60 40 20 0
Oh
         *1 Oh Nv                        4'     ~             ~'   ~       4410
: 1. 2/8/90 - Unit #1 Operational. Discontinued using treated surface water for potable use.
: 2. 2/2/93 - Unit #2 Operational

Attachment to TXX- O0*>15 Page 9 of 9                                FIGURE 2 ANNUAL AVERAGE GROUNDWATER LEVEL 1980 through 2007 (MSL)
Mean Sea Level Mean Sea Level (MSL) 620 f
Ann 580 560 OB-3 540 OB-4 520 500 480  I 46C"a                                                   . . I . .
q;o rell41 41}}